Five Parts of FAA Part 5 Safety Policy Documentation Compliance
FAA Part 5 compliance for Safety Policy is largely the concern of new aviation SMS programs.
Safety Policy requirements are mainly fulfilled in the first phase of aviation SMS implementation. Fortunately, the FAA’s compliance guidelines on this SMS Pillar are very clear, and well outlined.
The four parts of FAA Part 5 Safety Policy are:
- Safety policy statement (5.21);
- Safety accountability and authority (5.25(a)(b));
- Duties and responsibilities of accountable executive and safety management (5.25(c)); and
- Coordination of emergency response planning (5.27).
These four areas of safety policies are used to:
- Define safety performance objectives;
- Assign accountability;
- Allocate resources; and
- Define commitment to safety management.
Overall, various types of documentation are used to fulfill the safety policy goals above. Naturally, larger organizations will need more extensive safety policy documentation, and smaller organizations will need less extensive safety policy documentation.
Here are the four parts of FAA Part 5 Safety Policy pillar.
1 – Safety Policy
The FAA outlines specific items needed in aviation service providers’ safety policy statement. Here is what the FAA says should be included – we summarize these requirements into the most easily understandable language:
- Safety objectives of certificate holder;
- How organization is committed to fulfilling objectives;
- Outline of needed resources for fulfilling these objectives;
- List of required items for employees to report;
- Policy of unacceptable behavior (i.e., conditions for discipline);
- An emergency response plan (ERP, see 5.27) that allows organizations to safely meet emergency situations;
- Safety policy must be signed off by the accountable executive, who is responsible for the safety program (5.25);
- Safety policy needs to be communicated to everyone in organization, such as with required reviews, training, etc.; and
- Safety policy needs to be regularly reviewed.
Now, the safety policy should be concise. The purpose of this statement is not to detail “everything” about the program, but to provide:
- A useful, readable, document for all stakeholders;
- The “finish line” of what the company is aiming for in terms of safety; and
- A convenient place document to use to support safety decisions.
As the safety policy statement should be concise, and requires specific, short verbiage, the size of this statement should be similar in both small and larger organizations.
2 – Safety Accountability and Authority
The second part of the Safety Policy pillar is safety accountability and authority. The purpose of this element of Safety Policy is to map out:
- Who is responsible for what;
- The flow of safety information within the company; and
- The hierarchy of who makes safety decisions.
The Part 5 requirements for safety accountability and authority are that certificate holders define:
- Who the accountable executive is;
- All members of management that are responsible for hazard identification and risk assessment, risk control effectiveness, safety promotion, or monitoring safety performance;
- Employees within the cert. holder’s responsibility; and
- Levels of management with authority to make decisions of safety acceptability.
These requirements are usually fulfilled by creating:
- An SMS organization chart, listing each role in the SMS program and who each role reports to;
- A duties and responsibilities document, which lists each role in the program, and what elements of safety that role is responsible for, such as:
- Implementation of the SMS;
- Hazard identification;
- Monitoring of risk controls; and
- Safety performance monitoring.
- The accountable executive’s unique duties and commitment to developing the safety program.
The keyword here is “roles” in the organization. This is important to understand because even large organizations will have a similar set of roles as smaller organizations. Also, every organization will have a similar number of safety responsibilities. The outcome of these facts is that documentation of safety accountability and authority will be similar in scope for large and small organizations.
3 – Designation and Responsibilities of Required Safety Management Personnel
While the requirement is called “management personnel,” the first two parts of the Part 5 requirement for this element deals with the accountable executive. In fact, the Part 5 requirements don’t seem to indicate any needed output needed by the certificate holder, but rather simply outline how the FAA understands the accountable executive’s role in the SMS program:
- Is the final authority of safety operations;
- Controls financial resources;
- Controls human resources; and
- Is ultimately responsible for safety performance.
The accountable executive’s responsibility for these items is:
- Ensure implementation of the safety management system;
- Develop the safety policy;
- Communicate the safety policy;
- Review the safety policy to ensure that it’s current; and
- Review safety performance.
It would be a good idea to include in the safety policy statement how the accountable executive will fulfill these duties.
3.1 – Designation and Responsibilities of Management
Part C of this element of Safety Policy is to ensure that needed safety elements have enough manpower to oversee them. In other words, that there are enough management personnel to do what needs to be done.
While it seems an obvious activity, documenting who is doing what in the safety program is an excellent way of ensuring that a single role is not overloaded/underloaded with duties. This element requires that the following activities are designated to other managerial roles:
- Coordination of implementation, maintenance, and integration of SMS;
- Facilitate hazard identification and risk analysis;
- Monitor the effectiveness of risk controls;
- Ensure safety promotion throughout your organization; and
- Regularly report to accountable executive with safety performance information.
Remember that while the accountable executive is “responsible” for the above activities, that does not mean he/she needs to “carry the out.” It only means that he/she oversee their status.
4 – Emergency Response Planning (ERP)
The last element of the Safety Policy pillar in FAA Part 5 requirements is emergency response planning (5.27). This requirement is fairly straightforward. Aviation service providers like airlines and airports should develop emergency procedures that:
- Identify the authority of any given emergency type (a good idea is to also include each authority's contact information);
- Includes role-responsibility during a given emergency, such as the responsibilities of pilots, cabin crew, etc. during a flight emergency; and
- Ensure that your ERP does not conflict with the ERPs of other organizations that you interact with.
The last point requires that you do some legwork by contacting other organizations that you interact with, reading through their ERP, and ensuring that yours doesn't conflict with theirs.
Beyond this, you can create an emergency response plan and document it in a binder. Just makes sure that for compliance your ERP includes:
- Each type of emergency, such as Fire, Bomb Threats, etc.;
- Specific emergencies within that type, such as Hangar Fire, Airport Fire, Gas Fire, etc.;
- Authority(s) plus contact information to contact in each specific emergency;
- What the duties and responsibilities of each role are during each specific emergency; and
- SMS procedures that are relevant to each specific emergency.
For more information about FAA compliance, you will find these ebooks on FAA Part 5 compliance valuable: